Date: March 23, 2017
Issue: Corporate Governance;
Filing Type: Letter
Description: The Coalition welcomes the opportunity to comment on the final
rules issued by the Securities and Exchange Commission (the “SEC” or
“Commission”) under Section 953(b) of the Dodd-Frank Wall Street Reform and
Consumer Protection Act (“Dodd-Frank”), concerning the pay ratio rule.
The Coalition fundamentally believes that the pay ratio rule:
- Does nothing to advance the Commission’s tripartite mission of protecting investors, maintaining fair, orderly, and efficient markets, and facilitating capital formation;
- Fails to provide investors with any kind of material information to inform their decision making;
- Contributes to the phenomenon of “information overload” and makes the public company model even less attractive and;
- Imposes billions of dollars in costs upon public companies and their shareholders, distracts management from their core responsibilities, and provides no benefit to the American capital markets.